This Whistleblower Policy creates a process for internal disclosure of misconduct and other matters that should be disclosed to maintain good commercial practice and legal and ethical behaviour within your Company. It also protects those who disclose such conduct from reprisals from those affected by such disclosures, and outlines how disclosures will be handled. Under Part 9.4AAA of the Corporations Act 2001 (Cth), certain companies are required to have whistleblower policies that meet certain requirements. This policy meets those requirements. The companies required to have whistleblower policies include:

• Public companies.

• Proprietary companies that are the trustee of a registerable superannuation entity.

• Proprietary companies with a consolidated revenue of more than $50 million, consolidated gross assets of more than $25 million, or more than 100 employees.

Use this Whistleblower Policy if:

• You want to lay out your company's position in regards to commercial and corporate misconduct and the important of addressing it;

• You want employees to feel confident that they can report misconduct without fear of reprisals;

• You want to ensure that your company complies with the whistleblower protection provisions in the Corporations Act 2001 (Cth); and

• You want to minimise the company's liability for the misconduct of its employees.

What does this Whistleblower Policy cover?

• The types of conduct that may be reported under this policy;

• How that conduct may be reported;

• How reports will be handled so that misconduct is investigated and whistleblowers are protected; and

• The consequences for bringing negative consequences upon those who report misconduct.

Further information:

• New Whistleblower Laws: Everything You Need to Know